Modern Slavery & Human Trafficking Policy

This policy is stored electronically on the Syntria Sharepoint site in the ‘Admin / Policies’ folder

Policy Issue and Review Date

This policy was issued September 2024 and is due for formal review September 2025.

Policy Links

This Modern Slavery and Human Trafficking Policy should be considered in addition to the other related Syntria documentation listed below:

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• Syntria Data Protection Policy

• Syntria Staff Handbook

Our Operations and Supply Chains

Syntria Limited specialise in residential, commercial office design and fit out, and ancillary services including furniture supply within both the commercial and residential sectors.

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Syntria aim to ensure our same exacting standards include managing the risk of modern slavery and human trafficking in any part of our supply chain.

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Syntria employ many subcontractors as we primarily operate as a main contractor in both the residential and the commercial office fit out market and we have numerous suppliers, which has increased since inception of the business.

Our Modern Slavery and human Trafficking Policy

Syntria Limited. are committed to ensuring that there is no modern slavery, human trafficking or coercion of persons in our Company, in associated companies, subcontractors or labour only service providers.

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This policy reflects our commitment to acting ethically and with integrity in all of our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our, or any related Company.

Due Diligence - Potential Areas of Risk

Directly employed persons

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Syntria have a very small base of directly employed persons, and we never source our personnel from a labour agency, instead operating a direct interview process resulting in direct contracts. This negates any possibility that a person would not receive full remuneration for their work.

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We never seek to employ persons directly outside of the UK for our UK operations and require appropriate passports, permits to work and leave to stay in the UK prior to a person commencing work, thus negating any possible trafficking issues. All of our employees are paid directly into their own bank accounts by bank transfer, we do not allow for payment to third parties. Details of payments are shared digitally via a payslip detailing hours worked and any deductions for tax and social security.

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Additionally, all employees are vetted for the right to work in the UK

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Labour only contractors

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Syntria rarely employ labour only subcontractors to provide operatives and machine operatives on our sites.

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To mitigate the opportunity of trafficking, slavery or coercion we require confirmation that a subcontractor employs their own policy such as this prior to their employment by Syntria, which is reviewed and approved by means of an extensive subcontractor pre-qualification questionnaire process.

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Bona Fide contractors

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Syntria extensively employ bona fide contractors to provide specific and professional trades on our sites. To mitigate the opportunity of trafficking, slavery or coercion we require confirmation that a contractor employs their own policy such as this prior to their employment by Syntria, which is achieved by means of an extensive subcontractor pre-qualification questionnaire process.

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Suppliers

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Syntria utilise many suppliers in the delivery of our projects and are unable to monitor the policies of all of them. We do however favour uk-based suppliers who are also pre qualified and uphold our values as a business with regards to transparency and openness. We hold all suppliers to their legal requirements under the law and will report any circumstances we believe to be improper.

Adherence to this policy

If it is found that any person, company or agency associated with the Company is not abiding by the Slavery and Human Trafficking law then this will be reported to the appropriate authorities, and such person, company or agency will be suspended from use by the Company. In the case of an employee, disciplinary proceedings may result in Gross Negligence charges being brought, which would result in dismissal with prejudice.

Training

Relevant employees within Syntria are required to undertake an e-learning module to ensure they understand what Modern Slavery and Human Trafficking is, the laws around it, how to spot it in its different forms, how to raise concerns links to further reading.

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The Company commits to providing training to all operative personnel within our remit by way of continuous professional development training regarding modern slavery and human trafficking.